The American Hardwood Export Council explains its views on illegal logging and the actions it is taking to provide reliable assurances that American hardwoods derive from legal and sustainable source.
Illegal logging is a critical concern for the American hardwood industry. In addition to the deleterious impacts on biodiversity and other globally important environmental services and the damage caused to the overall reputation of the international wood industry, illegal logging has a direct impact on market access for American hardwood suppliers.
A recent study on the competitive impacts of illegal logging on the U.S. wood products concludes that illegal forest activity represents between 5% and 10% of global industrial roundwood production. The study suggests that as much as 23% to 30% of hardwood lumber and plywood traded globally could be of suspicious origin. The availability of significant volumes of illegal wood internationally depresses prices for US wood products by between 2% and 4%. In certain important markets, illegal material significantly affects the ability of US producers to export.
Therefore AHEC welcomes the efforts of European policy makers to play a leadership role in tackling the international problem of illegal logging. The European Commission’s Forest Law Enforcement and Trade (FLEGT) Action Plan has considerable potential to reduce imports of illegal wood into the EU. As part of the Plan, countries which are high risk from the perspective of illegal logging are encouraged to sign Voluntary Partnership Agreements (VPAs) with the EU. VPA countries will be required to ensure that all wood exported to the EU is covered by “legality licenses” providing independently verified guarantees that wood derives from legal sources.
The FLEGT Action Plan promotes development of government and corporate procurement policies in the EU favouring wood from verified legal and sustainable sources. Policy discussions are also underway in the EU on the potential for additional legislation designed to prevent imports of illegal wood into the EU.
American hardwoods should be major beneficiaries of these policy initiatives. Forestry laws are effectively enforced in the United States and there is a clear national commitment to sustainable forestry practices. There is long-term resource information showing that hardwood forests are thriving. Between 1953 and 2007, the volume of U.S. hardwood growing stock more than doubled from 5,210 million m3 to 11,326 million m3. U.S. federal government forecasts indicate that further increases of 15 to 20 percent are expected in the hardwood growing stock inventory through 2030.
But there are also challenges for American hardwoods. While there is readily available resource information to indicate that American hardwoods derive from sustainable sources, only a small proportion of these hardwoods may be supplied as independently certified product. The vast majority of American hardwood derives from the eastern United States where there are approximately 4 million private forest owners with an average lot size of 50 acres. A key challenge is to generate awareness and support for certification amongst this huge and diverse constituency of small forest owners. According to a recent survey, forest certification systems (including ATFS, FSC and SFI) have very low participation (2%) and very low awareness (17%) amongst U.S. family forest owners. There is a need to encourage small owners to work together in a sector where there is little or no tradition of co-operative action. Fragmentation of forest ownership also means that it is extremely difficult to trace wood from individual forest to point of sale.
It is notable that a major factor preventing widespread forest certification in the American hardwood sector has also made a significant contribution to the legal and sustainable management of the nation's forests. The dominance of small non-industrial forest owners has meant there is a strong link between the U.S. population and their forests.
Around 4% of the total U.S. population directly own forest lands. Through living and working in the forests all their lives, many U.S. citizens have gained a deep understanding of forest management. Lack of certification does not imply lack of sustainability in the context of American hardwoods.
Nevertheless, some European governments and companies tend to regard “legal and sustainable forest management” as the same thing as “certified forest management”.
National governments are introducing procurement requirements specifying that wood must be traceable to forest of origin and independently certified as legal and sustainable. European policy makers are being encouraged in this approach by domestic suppliers that are already marketing certified wood products. In addition they are influenced by FLEGT VPA legality verification mechanisms being developed for high risk countries which also emphasise full traceability and third party independent verification.
So how is it possible to bridge the gap between emerging European demands for assurances that wood is from legal and sustainable sources, and the difficulties of establishing traceability and independent certification in the American hardwood sector?
AHEC believes that the answer lies in more widespread use of risk assessment procedures. Use of risk assessment has the great advantage of avoiding the imposition of unnecessary controls and costs on suppliers in regions where illegal logging and unsustainable practices are not a problem. It means that time, resources, and requirements are focused on areas and suppliers where problems do exist.
Risk assessment is already widely applied by the European private sector as a tool to avoid trade in wood from illegal and other controversial sources. Both FSC and PEFC have developed procedures for risk assessment as part of their Chain of Custody standards. The UK Timber Trade Federation’s Responsible Purchasing Policy (RPP) requires risk assessment as a critical first step in the development of corporate action plans. Similarly, risk assessment is an integral part of the procedures applied by members of the WWF’s Global Forest and Trade Network (GFTN) including B&Q, Homebase, Marks and Spencer, Travis Perkins and Jewson.
The World Resources Institute has also recently issued a guide for “Sustainable Procurement of Wood and Paper-based products” that relies on risk assessment for making purchasing decisions.
AHEC has assisted companies to comply with these initiatives by commissioning a comprehensive data-based assessment of the risk that American hardwoods derive from illegal and other controversial sources including all five categories of unacceptable source defined in the FSC controlled wood standard.
The study has been undertaken by a team of independent and internationally-renowned academics and consultants with detailed knowledge of US forestry policy and practices. Results from the research, due to be released in the next few weeks, indicate that there is a low risk of any hardwood sourced from the United States being derived from an illegal source or any category of source regarded as unacceptable by FSC.
While risk assessment is integral to many private sector initiatives, the concept has not yet been fully integrated into European public sector timber procurement policies. At present these policies - while providing some scope for use of risk assessment in legality verification - tend to accept only forest certification as evidence of sustainability. However AHEC believes that there is no practical reason why assurances of sustainable forestry practices cannot also be provided by means of a comprehensive risk-analysis. AHEC believes that while this approach is not universally applicable, it is appropriate under certain specified conditions:
• when dealing with forests that are managed at relatively low intensity by small family forest owners in regions where there is clear evidence of good governance;
• and where rigorous independent research has been undertaken to provide an assurance of low risk.
AHEC is now developing these ideas in consultation with European procurement officials and AHEC members.
AHEC is also concerned that current deliberations in Europe over the introduction of new legislation designed to prevent imports of illegal timber take full account of the risk-based approach. One option being considered by the European Commission, which would require all suppliers of wood imported into the EU to provide proof of legality, seems disproportionate to the scale of the problem and would impose unnecessary controls on all suppliers irrespective of the risk of illegal logging.
Another option is for the EU to mirror new legislation just introduced in the U.S. with the strong support of the American hardwood trade and industry.
In May 2008, the U.S. legislature passed an amendment to the Lacey Act so that U.S. companies may be prosecuted if it can be shown that they imported a consignment of timber in the knowledge that it came from an illegal source. This law is expected to encourage more widespread uptake of risk assessment by US importers, placing greater demands on high risk countries to provide reliable assurances that wood is legally sourced.
If a similar law were passed in the EU, it could play an important role in preventing imports of illegal wood while avoiding the imposition of unnecessary additional controls on countries where there is a low risk of illegal logging.
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